🎙️ Story: The Case That Changed the Definition of “Industry” Forever

Once upon a time in the bustling city of Bangalore in the 1970s, a legal storm was quietly brewing within the walls of a government-run utility – the Bangalore Water Supply and Sewerage Board.

💧 The Setting

The Bangalore Water Supply and Sewerage Board (BWSSB) was no ordinary office. Tasked with the essential duty of providing clean water and managing sewage systems, it had hundreds of employees working tirelessly behind the scenes to keep the city running.

But all was not well. The employees felt they were being treated unfairly. There were disputes about working conditions, grievances about rights, and a pressing need for their voices to be heard. So, they did what Indian workers had done for decades — they raised an industrial dispute.

⚖️ The Twist

But here’s where the story takes a turn.

The management of BWSSB pushed back. Their defense?
“We are not an industry. We’re a statutory body, created to serve the public. Industrial Disputes Act does not apply to us.”

The workers were stunned. If the board wasn’t an “industry,” how would their rights as workers be protected under labour laws? Was providing water not a service? Was this massive organisation not employing hundreds of people?

The legal question snowballed. What exactly is an “industry”? And more importantly, who is a worker?

🏛️ Enter the Supreme Court

The case finally landed in the Supreme Court of India — and not before a regular bench. This was big. So big that it went before a seven-judge Constitution Bench, one of the rarest and most powerful benches of the Court.

At the helm was the eloquent and sharp Justice V.R. Krishna Iyer.

He listened, reflected, and then asked the most basic question:

“Is providing essential services like water and sanitation not a systematic activity, organized by people, to meet human needs?”

The answer was clear. Yes, it was.

⚖️ The Landmark Judgment

On 21st February 1978, the Supreme Court delivered a judgment that shook the foundations of Indian labour law.

The court expanded the definition of “industry” like never before. It introduced the now-famous Triple Test:

1. Is there a systematic activity?
2. Is there cooperation between employer and employees?
3. Is the activity aimed at satisfying human wants or needs?

If yes, then it is an industry — even if it doesn’t make profits.

Hospitals, educational institutions, charitable organizations — if they met the test, they too were industries now.

🚫 Not Everything is an Industry

But Justice Krishna Iyer drew a line in the sand.

Activities that are purely sovereign functions — like the military, police, judiciary, or law-making — would be excluded. They were part of the state’s core authority, and not subject to the same industrial framework.

🌊 The Ripple Effect

The decision in Bangalore Water Supply v. A. Rajappa became the gold standard. It expanded the rights of millions of workers in India who were earlier in legal grey zones. It ensured that being a statutory or charitable body was no excuse for bypassing labour rights.

But it also brought challenges. Employers worried about compliance burdens. Policy makers debated over the “too broad” definition. Yet, for workers, it was a watershed moment.

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🧾 Epilogue: A Judgment Ahead of Its Time

Even today, lawyers, judges, and HR professionals go back to this case. It’s cited in law schools, argued in courts, and discussed in Parliament.

The Bangalore Water case is more than just a legal precedent — it’s a story of how the law sided with the working class, recognized dignity in all labour, and reminded the nation that justice flows not just in courtrooms, but also through the taps and drains of our cities.